Debra Ann King v. United States Government

• Court: District Court, E.D. Michigan
• Decided: June 25, 2026
• Docket: 2:26-cv-12023
• Status: Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

DEBRA ANN KING,

Plaintiff, Case No. 2:26-cv-12023

v. Hon. Brandy R. McMillion United States District Judge UNITED STATES GOVERNMENT,

Defendant. /

ORDER OF SUMMARY DISMISSAL

Plaintiff Debra Ann King (“King”) filed this pro se action against Defendant United States Government (the “Government”) for violations of the Thirteenth and Fourteenth Amendments to the U.S. Constitution, seeking reparations for the slavery of her great, great grandparents and the resulting unjust treatment and lack of freedom, liberty and the pursuit of happiness for their descendants from 1619 to 2026. See generally ECF No. 1. Concurrent with filing the Complaint, King also filed an Application to Proceed Without the Prepayment of Fees (in forma pauperis). ECF No. 2. The Court has reviewed the Application, finds King to be indigent, and therefore GRANTS the application to proceed in forma pauperis. However, because the Court lacks jurisdiction over King’s claims, this case is SUMMARILY DISMISSED. * * * * King filed this action alleging that African-Americans, including her great, great

grandmothers, were “held in forced slavery,” subject to “oppression and other types of laws [that were] used to take our wealth, labor and freedom.” ECF No. 1, PageID.5. As a result, she alleges that she “continue[s] to struggle without any inheritance or

payment for past wrongs” and “continue[s] to suffer under unjust laws and [violations of her] USA Constitutional rights to freedom, liberty and the pursuit of happiness.” Id. She seeks $75,000,000 in reparations. Id. Under Federal Rule of Civil Procedure 12(h)(3), if the “court determines at any

time that it lacks subject-matter jurisdiction, the court must dismiss the action.” Houston v. Garland, No. 2:22-cv-13036, 2023 WL 3212335, at *2 (E.D. Mich. May 2, 2023), aff'd, No. 23-1530, 2024 WL 1925936 (6th Cir. Jan. 26, 2024). Although the

Court should remain mindful that pro se complaints are to be construed liberally, pro se complaints “must still satisfy the subject matter jurisdiction requirement.” Lopez v. Benson, No. 2:24-cv-10916, 2024 WL 3740115, at *1 (E.D. Mich. June 6, 2024). Federal Courts have jurisdiction over two types of cases: (1) cases presenting a federal

question arising under the United States Constitution, federal laws or treaties, pursuant to 28 U.S.C. § 1331; and (2) cases based on diversity of citizenship where a citizen of one state sues a citizen of another state or nation and the amount in controversy exceeds

$75,000, pursuant to 28 U.S.C. § 1332. However, the Political Question Doctrine prohibits federal courts from adjudicating disputes that have been committed by the Constitution to another branch

of government. See Baker v. Carr, 369 U.S. 186, 2111 (1962). Several courts, within this circuit and outside the circuit, have found that a claim for reparations from the descendants of enslaved people are non-justiciable political questions that the federal

courts do not have jurisdiction to decide. See Clarke v. United States, No. 25-CV- 02083-SHL-TMP, 2025 WL 1628020, at *2 (W.D. Tenn. Feb. 27, 2025), report and recommendation adopted, No. 2:25-CV-02083-SHL-TMP, 2025 WL 1342959 (W.D. Tenn. May 8, 2025); Chilton v. United States, No. 1:23-cv-188, 2024 WL 694367, at

*2 (W.D. Mich. Jan. 24, 2024), report and recommendation adopted, 2024 WL 688430 (W.D. Mich. Feb. 20, 2024); Hannon v. Lynch, No. 2:15-CV-0718, 2016 WL 491831, at *2 (S.D. Ohio Feb. 9, 2016); see also Hawk-Bey v. United States, 477 F. App’x 864,

865-66 (3d Cir. 2012), In re African-Am. Slave Descendants Litig., 375 F. Supp. 2d 721, 765-66 (N.D. Ill. 2005), aff'd in part as modified, rev’d in part, 471 F.3d 754 (7th Cir. 2006). Consequently, the Court lacks jurisdiction to proceed with this action. * * * * Accordingly, Plaintiff’s Complaint (ECF No. 1) is SUMMARILY

DISMISSED. This is a final order that closes the case. IT IS SO ORDERED. Dated: June 25, 2026 s/Brandy R. McMillion Detroit, Michigan H .B R.M M